PRINCIPAL COMMISSIONER OF INCOME TAX 1 KOLKATA vs. M/S ITC LTD
ITAT/89/2025HC Calcutta21 Jul 2025
Bench: The Learned Tribunal – One By The Assessee & The Other By The Revenue Which Have Been Disposed Of By A Common Order, Impugned In This Appeal. 2. The Revenue Has Raised The Following Substantial Questions Of Law For Consideration :
For Appellant: Mr. Prithu Dudhoria, AdvocateFor Respondent: Mr. J.P. Khaitan, Senior Advocate
Section 14ASection 260ASection 37(1)Section 40a
disallowance of
Rs.21,16,23,729/- of interest in terms of Section 14A of the Income Tax
Act, 1961 read with Rule 8D (2)(ii) of the Income Tax Rules 1962,
without considering the fact that the assessee was having interest
bearing borrowings which were used for mixed purposes including
investment and without appreciating the effect of the clarificatory
amendment